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This letter conveys my thoughts on the Draft Guidelines for
Accessible Public Rights-of-Way with respect to persons with
vision impairment. The installation of accessible pedestrian
signals (APS) along with detectable warnings at street crossings
will enable me to travel more safely. It is very important for
the APS to have a locator tone to help the visually impaired find
the pushbutton and that it have audible output to signal the onset
of the walk phase. The manner in which the accessible pedestrian
signal communicates to the blind pedestrian is important. The
current MUTCD allows the communication to be either tactile or
auditory. The sound levels produced by newer APS equipment
respond to ambient background level and can only be heard a short
distance from the pushbutton. They should not be audible to
neighboring residences and businesses. If members of the Access
Board receives comments from organizations that these sound levels
are not acceptable on a routine bases, then please consider having
the audible output be produced after continuously pressing the
pushbutton for three seconds. The APS equipment would communicate
that the auditory output has been activated by either briefly
vibrating the pushbutton or by giving a verbal message. Note that
a resolution supporting the three-second activation was ratified
at the July 2002 American Council of the Blind (ACB) national
convention in Houston. The three-second activation would
accomodate the members of the National Federation of the Blind
(NFB) who prefer vibro-tactile output without sound. An
accessible pedestrian signal does not reduce the safety of the
elderly or people with other types of disability. Indeed, if a
three-second activation is needed, they would learn its proper use
after reading the face plate of the pushbutton or after hearing a
public service announcement.

The installation of accessible pedestrian signals should be
routine rather than the exception since it is often necessary to
travel to locations which are scattered across several cities in
the area. City traffic engineers are often not responsive when
requests for accessible pedestrian signals are made by blind
persons from other cities. The routine installation of APS
equipment for new signalized intersections and the upgrading of
old signalized intersections when they finally need repair is very
important for the safety of visually impaired pedestrians. The
cost of implementing this recommendation is spread over a long
period of time since pushbuttons only fail after many years of
service. Although an APS is more expensive than an ordinary
pedestrian pushbutton at this time, its price would be appreciably
lowered when major manufactures compete to meet the demand created
by their routine installation. The Access Board can provide the
impetus to these manufacturers by requiring their routine
installation.

Accessible pedestrian signals now emit a variety of audible output
such as bird-call tones, verbal messages, and buzzing or clicking
sounds. Since the optimum auditory output for APS equipment is an
ongoing subject of research, it would be wise to require this
equipment to have a digital sound chip. When the optimum auditory
output is determined, the digital sound chip can easily be
reprogrammed to produce it. Otherwise, the equipment would have
to be replaced.

The detectable warning is also very helpful for pedestrian safety.
Some of the ramps in Menlo Park are so smooth that I have found
myself in the street without realizing it. A Crosswalk with
complex or unusual geometry often creates difficulties for
visually impaired pedestrians. It would be useful to have a guide
strip within the crosswalk or, alternatively, to have the material
within the crosswalk be easily distinguishable from the rest of
the pavement. The guideline which keeps signs from protruding
more than four inches from the pole from 27 to 80 inches off the
ground is also very much appreciated.

I hope one day to be able to approach any busy intersection with
the assurance that it is safe for me to cross it. Please retain
detectable warnings and the routine installation of accessible
pedestrian signals with audible output in the guidelines.

Thank you for the opportunity to convey my thoughts to you on this
important issue.

Sincerely,

Ezio Alviti